Maria Alejandra (Jana) del-Cerro
Overview
Maria Alejandra (Jana) del-Cerro is a partner in Crowell & Moring's Washington, D.C. office and a member of the firm’s International Trade and Government Contracts groups. She advises clients with respect to the U.S. regulation of outbound trade, including U.S. export controls. Jana works with clients across a broad range of industries, from traditional aerospace and defense manufacturers and multi-national software companies, to start-ups in the technology sector, and she regularly represents them before the Departments of State, Commerce, and Treasury in responding to government inquiries, conducting internal reviews, and in compliance investigations and voluntary disclosures. Jana previously worked at the Department of State’s Directorate of Defense Trade Controls (DDTC) and currently serves as a member of the U.S. Department of State Defense Trade Advisory Group (DTAG).
Career & Education
- Department of State
- Member, Defense Trade Advisory Group, 2024–Present
- Regulatory and Multilateral Affairs Analyst, Policy Office, Directorate of Defense Trade Controls, 2021–2022
- Department of State
- University of Virginia, B.A., history, 2004
- American University Washington College of Law, J.D., With Honors, 2008
- American University School of International Service, M.A., international affairs, 2008
- District of Columbia
- Virginia (Inactive)
Jana's Insights
Client Alert | 8 min read | 10.09.24
The Month in International Trade – September 2024
This news bulletin is provided by the International Trade Group of Crowell & Moring. If you have questions or need assistance on trade law matters, please contact Jana del-Cerro, Anand Sithian, or Simeon Yerokun or any member of the International Trade Group.
Event | 09.25.24
Speaking Engagement | 09.25.24
"EAR 734.99 (b) and Foreign Direct Product Rule (FDPR) and 734.4/de minimis Thresholds: How to Apply Complex Requirements in Practice and Avoid the Key Compliance Traps," ACI's Practical Forum on Advanced EAR Compliance
Representative Matters
- Advised on legal strategy and managed export attorney and consultant teams in multinational corporation’s internal investigation arising from apparent transfers and storage of ITAR and EAR-controlled technical information in a cloud-based global network.
- Represented large defense contractor in investigation and voluntary disclosure to DDTC in connection with overseas payments of fees and commissions, and related reporting under ITAR Part 130 to DDTC.
- Counseled non-U.S. semiconductor manufacturing equipment producer on applicability of EAR end user and end use licensing requirements, and the EAR Foreign Direct Product Rules, on client’s sales throughout Asia.
- Directed export classification review of a quantum company’s hardware and related technology and software, as well as navigating changing EAR export controls on quantum technologies, and assisted company with development of policies and procedures to enhance export compliance.
- Managed a global sensors and electronics companies’ internal investigation of overseas production of export-controlled sensor and related unlicensed technology transfers, and represented the client in a related voluntary self-disclosure to BIS.
- Assisted client with internal investigation and represented client in voluntary self-disclosure to BIS regarding sales of engineering software to Entity List party subject to a BIS heightened Foreign Direct Product rule, and performed U.S. export jurisdictional analysis of the software involved.
- Represented aerospace and defense contractor in internal review of export control policies and procedures, and assisted in responding to DDTC Requests for Information regarding foreign person access to technical data.
- Assisted client in internal investigation of foreign affiliate sales to Russian distributors, including transactional analysis of items exported since 2022, and represented client in voluntary self-disclosure to BIS.
- Provided legal advice for client’s export classification review of entire UAV system, including preparing and submitting export commodity classification requests to BIS regarding various software packages and related technology.
- Regularly performs encryption classification analyses, submits commodity classification requests, oversees submission of license applications, and counsels on compliance with Department of Commerce encryption reporting requirements for Fortune 500 and Fortune 100 software and technology companies.
- Regularly counsels large multinational software developers with respect to cross-border sales of software and the provision of cloud-based software services in compliance with U.S. export controls and sanctions laws, and regularly obtains Department of Commerce export licenses to support non-U.S. customer activity.
- Developed global sanctions and export compliance programs for distributed database technology company, including procedures for determining applicability of U.S. encryption controls and for controlling technology and source code transfers.
- Represented Fortune 100 information technology company in voluntary disclosure to the Department of Commerce for unauthorized exports of U.S. origin encryption restricted servers and related software to a number of countries across Asia.
- Assisted international consulting and professional services company with classification of cyber security software solutions, with a focus on USML Category XIII(b) and encryption controls under the EAR, and drafted tailored compliance policies and training.
- Prepared commodity classification request for forensic software company, and prepared related voluntary disclosure and waiver request to BIS.
- Analyzed export classification and submitted commodity jurisdiction requests for defense simulation, training, and modeling software.
- Analyzed export classification of multi-axis rate tables and prepared successful commodity classification request for reclassification of rate tables and related technology, and provided general export compliance counseling regarding exports of rates tables in compliance with EAR Part 744 restrictions.
- Developed export compliance program for international methanol and petrochemical manufacturers with U.S. operations, and provided counseling on compliance with U.S. export and sanctions requirements.
Jana's Insights
Client Alert | 8 min read | 10.09.24
The Month in International Trade – September 2024
This news bulletin is provided by the International Trade Group of Crowell & Moring. If you have questions or need assistance on trade law matters, please contact Jana del-Cerro, Anand Sithian, or Simeon Yerokun or any member of the International Trade Group.
Event | 09.25.24
Speaking Engagement | 09.25.24
"EAR 734.99 (b) and Foreign Direct Product Rule (FDPR) and 734.4/de minimis Thresholds: How to Apply Complex Requirements in Practice and Avoid the Key Compliance Traps," ACI's Practical Forum on Advanced EAR Compliance
Insights
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05.03.24
The Government Contracting Law Report
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04.17.24
The Government Contracting Law Report
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06.15.23
Government Contracting Law Report
Commerce Publishes ANPRM Seeking Comment On The Licensing Process For ICTS Transactions
|04.28.21
Westlaw Today
How To Prepare For CFIUS-Related Questions From Potential Investors
|09.01.20
Foreign Investment Watch
Lifting 40-year Ban on Exporting U.S. Crude Oil: Senate Energy Committee Chair to Introduce New Bill
|04.22.15
Crowell & Moring's Public Policy Bulletin
Export of Energy Commodities Part of House Energy and Commerce Committee's 'Architecture of Abundance' Framework
|02.10.15
Crowell & Moring's Public Policy Bulletin
"EAR 734.99 (b) and Foreign Direct Product Rule (FDPR) and 734.4/de minimis Thresholds: How to Apply Complex Requirements in Practice and Avoid the Key Compliance Traps," ACI's Practical Forum on Advanced EAR Compliance
|09.25.24
"International Trade - Navigating the Maze of Global Sanctions: A Business Perspective," Inter-Pacific Bar Association Conference, Tokyo, Japan
|04.26.24
"How Compliance Decision-Makers are Dovetailing Multi-Jurisdictional Export Requirements for Effective Global Compliance Program Customization," ACI’s Advanced Forum on Global Export Controls, Washington, DC
|02.28.24
Inter-Pacific Bar Association (IPBA) Los Angeles Conference: Doing Business with Asia: IP, Trade, and Investigation
|02.01.24
Trade Consultant Fears Australian Industry 'Not Ready' for AUKUS Exemptions
|05.15.24
Export Compliance Daily
Banks Need Better Data to Catch Export Control Evasion, Industry Official Says
|04.05.24
Export Compliance Daily
CFIUS Focuses On Chips, Lawyers Say; Expert Seeks Balanced US Approach To China
|06.25.20
Communications Daily
- |
09.18.24
Crowell & Moring’s International Trade Law
OFAC, State Department, and BIS Expand Russian/Belarusian Sanctions
|08.28.24
Crowell & Moring’s International Trade Law
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08.16.24
Crowell & Moring’s International Trade Law
ITAR and EAR Proposed Rules Expand Controls on U.S. Person Services
|07.25.24
Crowell & Moring’s International Trade Law
BIS Issues “Best Practices” Guidance for Mitigating Export Diversion Risk
|07.11.24
Crowell & Moring’s International Trade Law
BIS Streamlines Export Controls for Transfers to and Among Australia and the UK
|04.22.24
Crowell & Moring’s International Trade Law
New U.S. Sanctions and Export Controls Imposed on Iran Following Recent Attacks on Israel
|04.22.24
Crowell & Moring’s International Trade Law
BIS and DDTC Amendments Add Nicaragua to EAR Country Group D and ITAR § 126.1
|03.19.24
Crowell & Moring’s International Trade Law
- |
02.23.24
Crowell & Moring’s International Trade Law
Jana's Insights
Client Alert | 8 min read | 10.09.24
The Month in International Trade – September 2024
This news bulletin is provided by the International Trade Group of Crowell & Moring. If you have questions or need assistance on trade law matters, please contact Jana del-Cerro, Anand Sithian, or Simeon Yerokun or any member of the International Trade Group.
Event | 09.25.24
Speaking Engagement | 09.25.24
"EAR 734.99 (b) and Foreign Direct Product Rule (FDPR) and 734.4/de minimis Thresholds: How to Apply Complex Requirements in Practice and Avoid the Key Compliance Traps," ACI's Practical Forum on Advanced EAR Compliance